Taxation of the Digital Economy Update: OECD consultation

On 9 October 2019, as part of the ongoing work of the G20/OECD Inclusive Framework (Inclusive Framework) on Base Erosion and Profit Shifting, the OECD released a public consultation document containing a Secretariat Proposal for a "Unified Approach" under Pillar One. The proposal from the OECD Secretariat is designed to attract enough governmental support to lead to consensus among the G20/OECD Inclusive Framework participating countries.

This publication follows on from the programme of work issued on 31 May 2019, and seeks to harmonise aspects of the three initial proposals around user participation, marketing intangibles and significant economic presence in order to develop a possible new approach.

The proposal under Pillar One grants greater taxing rights to market jurisdictions. This is intended to ensure greater taxation in jurisdictions where significant business is conducted, even without a physical presence. It is set out at a high level to include key features but will require further detailed work. It does not, at this stage, have consensus political support from the more than 130 governments participating in the Inclusive Framework.

The OECD invites comments from the public with a view to discussing the results during a public consultation on 21-22 November 2019. Interested parties are invited to send their comments by email to the OECD no later than 12pm (Paris time) on 12 November 2019.

If you have any comments to make please contact Angela Clegg at